Item 5 - Fees and Compensation
Prior to engaging RVP to provide any of the foregoing investment advisory services, the
client will be required to enter into one or more written agreements with RVP setting for
the terms and conditions under which RVP shall render its services (collectively the
"Agreement"). This Agreement sets for the fee the Client will pay, on an annual basis, to
RVP for its money management services.
Management Fees
If engaged, RVP shall charge an annual fee based upon a percentage of the market value of
the assets being managed by RVP. The annual fee shall vary (between 0.50% and 1.25%)
depending upon the market value of the assets under management, the type of investment
management services to be rendered and any breakpoints. Generally, RVP’s fee schedule
is as follows:
Strategy/ Fixed Balanced Equity Absolute Durable Disciplined
Assets Income Return Opportunities ETF
First $ 3mm 0.75% 1.20% 1.25% 1.25% 0.90% 0.95%
Next $ 7mm 0.65% 0.90% 1.00% 1.25% 0.90% 0.75%
Next $15mm 0.50% 0.75% 0.85% 1.25% 0.90% 0.60%
$25mm + 0.50% 0.60% 0.75% 1.00% 0.90% 0.55%
The strategies above are the broad asset class descriptions and there may be more specific
strategies under each category. For instance, Fixed Income refers to all Fixed Income
strategies managed by RVP.
In addition to the investment management strategies described above, RVP offers Wealth
Management which is typically a combination of the actively managed strategies listed
above, other passive investments such as ETFs or mutual funds and financial planning.
Wealth Management may also include holdings that were transferred in by the client. The
Wealth Management fee is the only fee the client will pay to RVP, even if the client is
invested in RVP investment management strategies through the Wealth Management
portfolio. RVP’s fee schedule for Wealth Management is, generally:
Assets/Strategy Wealth Management
First $ 3mm 0.95%
Next $ 7mm 0.75%
Next $ 15mm 0.60%
$ 25mm + 0.55%
RVP also provides a service of offering investments in private funds to those clients for
whom it believes the offering may be suitable. RVP will establish general parameters of
risk tolerance, liquidity, cash flow, age and net worth in order to determine that suitability.
RVP will charge up to 75 basis points on the value of the private funds for clients that use
this service, unless it is part of the Wealth Management portfolio in which case the single
wealth management fee described above is all that is charged. The fee amount will be
billed the same as RVP’s current practice of quarterly, in arrears, based upon the average
daily balance of the investment as of the billing quarter.
RVP's annual fee shall be prorated and charged quarterly, in arrears, based upon the
average daily market value of the assets over the quarter, including the value of cash,
accrued interest and accrued dividends in the client’s account. RVP reserves the right to
waive a client’s fees and RVP’s annual fee is negotiable. RVP will calculate and deduct the
fee from the client’s account at the end of each quarter. A client can request to be billed
for the fees incurred but RVP reserves the right to deny this request. Requests will be
addressed on a case by case basis.
To the extent that a client authorizes the use of margin, and margin is thereafter employed
by RVP in the management of the client's investment portfolio, the market value of the
client's account and corresponding fee payable by the client to RVP will be increased to
reflect the margin and will be based on the total assets invested.
For certain clients, we charge an advisory fee for services provided to held-away accounts
mentioned above in Item 4 as “Assets under Advisement”, just as we do with client
accounts held at our primary custodian(s). The specific fee schedule charged by us is
provided in the client’s investment advisory agreement with us.
Non-Discretionary Management and Financial Counseling
If the firm provides non-discretionary assets management and financial counseling, it will
charge its fees as either a fixed fee or a percentage-based fee based upon assets under
management. The fixed fee is payable quarterly, in arrears, and there is a minimum fixed
fee of $25,000 per year. The percentage fee is charged quarterly, in arrears, based on the
average daily balance of the assets under management over the quarter.
Clients that transferred to RVP’s management from an acquisition of certain advisory
practices have their fees grandfathered in. These fees may be lower than clients who
engage RVP after January 1, 2022, and are not available to new or other clients of RVP.
RVP's Agreement and/or the separate agreement with the Custodian of Client Assets
(Financial Institution(s)) may authorize RVP through the Financial Institution(s) to debit the
client's account for the amount of RVP's fee and to directly remit that management fee to
RVP in accordance with applicable custody rules. The Financial Institution(s) recommended
by RVP have agreed to send a statement to the client, at least quarterly, indicating all
amounts disbursed from the account including the amount of management of fees paid
directly to RVP.
The allocation of SWP client assets to RVP through a subadvisor relationship, rather than
to an unaffiliated investment manager increases RVP’s compensation and the revenue to
RVP and SWP’s parent company, Focus LLC. As a consequence, the common parent
company has a financial incentive to cause SWP to recommend that SWP’s clients’ assts be
managed by RVP.
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